Kurt Zaner

Premises cases are some of the best to take to trial - always a corporate defendant and always lots of coverage. However, there are complex liability theories, challenging causation issues, and several entities usually on site. From Slip and Falls to Electrocution and Explosions, every Premises Liability case has its own unique challenges. But there is a method to winning – and winning big. With verdicts of 16M, 10.6M, and 30M in Premises cases, Kurt Zaner has fine-tuned his patented approach and will be sharing it with all attendees.

1. Building the case

a. Case selection

b. Early Actions

i. Site inspections,

ii. Expert hires,

iii. Case evaluations

c. Experts

i. What kind to hire – architects, engineers, human factors, regulators, etc.

ii. When do you hire

iii. Best places to find them

d. Discovery Plan

2. Filing the Case

a. Setting up the claims and parties

b. Pleading PLA v. Negligence

3. Document Discovery

a. Documents needed

b. Discovery Request Strategy

c. ESI

4. Deposition discovery 30b6 Depos

a. 30b6/PMKs

i. Topics

ii. Depo strategy

iii. Rules of the Road

iv. When to press

b. Fact witnesses

c. Order of depositions

d. Your client’s deposition

5. Trial Preparation

a. MILS

b. Demonstratives v. Chart Paper

c. Focus groups

d. Order of witnesses

6. Jury Selection in Premises Cases

a. Questions you must ask

b. Questions you would like to ask

c. Questions you shouldn’t ask.

7. Opening

a. Educate, inform, and planting seeds

b. Diffusing defenses

c. Introducing clients damages

8. Cross of Defense Witnesses

a. Strategy

b. Drama

c. Depo Clip Integration

9. Closing and Rebuttal

a. Will demonstrate PLA closing with slide deck

b. What to save for rebuttal – briefcase decisions?